From: gthomas@bp.Guardian.com

To: Susan Fairchild/RTP/USEPA/US@EPA

Date: 03/02/2012 07:10 PM

Subject:Guardian Inwood Preliminary Test Results

Susan, as you requested, I am forwarding the preliminary test results of the final deliverables you 

requested for the Inwood furnace stack. See the pdf files attached to the email below. The QAQC is 

completed and so I do not expect any changes in test results, as there were none with the Kingman test 

results in the final report we received today.

As the test contractor commented below, the Inwood test results were very good and that is not totally 

surprising as the filter media in this baghouse is unique. As you recall, we requested to install PTFE 

filters in the Inwood baghouse and it looks like this media does drive down emissions somewhat when 

compared to the other furnaces we have tested.

Though you did not require us to conduct a Method 5/202 PM determination, these test methods were 

referenced in the proposed rule and we wanted to determine if a baghouse with PTFE filter media would 

meet the 0.014 lb/ton

proposed standard. We did not pay the test company to expedite the 202

results but expect to have the 202 results by next Friday, March 9th. I will forward the results to you as 

soon as they arrive.

The PM filterable Method 5 and Method 29 are attached below and both test methods resulted in 

exactly the same results of 0.008 lb/ton, which is below the 0.014 lb/ton proposed standard and also 

lower than the other four

(4) furnaces that were tested at Guardian. Though we are elated at the lower emissions with PTFE filter 

media, it remains to be seen if we can still meet the proposed standard after adding in the backhalf 202 

condensible PM emissions. We will find out a week from now.

You indicated the MACT floor for PM may be relaxed due to some issues with the original data set. 

Nonetheless, it is our understanding the MACT floor was based on filterable emissions only and did not 

include condensible PM emissions. If this is the approach to calculate the MACT floor, the proposed PM 

Method should be Method 5 and/or Method 29, not a combination

of Method 5 and Method 202. If Method 5/202 is going to be the

proposed

PM method in the final rule, than the MACT floor needs to be based on Method 5/202 data.

The Method 0061 chrome results for the Inwood furnace were slightly lower compared to the Method 

29 chrome results but the same order of magnitude.

The Method 29 chrome results for Inwood were also slightly lower compared to the Method 29 chrome 

results for the other four furnaces already tested (Albion, Inwood, Kingman & Winnsboro) but the same 

order of magnitude, but probably slightly lower due to using the PTFE filter media.
Unlike Kingman, the magnitude of the vaporous back half chrome emissions were about the same order 

of magnitude as front half filterable emissions.

You may recall in Kingman, the filterable front half represented over 80%

of the chrome. Obviously, the Inwood PTFE filter media is removing

more

filterable chrome and so you would expect the filterable front half and vaporous back half to be more 

closely the same.

Not surprisingly, the hexavalent chrome emissions continue to be very low, about half the magnitude of 

the total chrome emissions and the same order of magnitude of the furnaces already tested (Albion, 

Inwood, Kingman & Winnsboro).

We also tested HF and HCL and these emissions were the among the lowest emissions we have seen 

compared to the other furnaces tested in Albion,

Inwood, Kingman and Winnsboro and below the proposed standard. We wish

all of our plants were this low but we believe these emissions are more of function of the purchased 

cullet and it would be unfortunate that the HF and HCl standard is not relaxed to continue to encourage 

recycling of cullet and in so doing, promote energy savings and reduction of greenhouse gases.

We are elated at the emission results for Inwood and that all of our furnace results are fairly consistent. 

In sum, the emissions for the five

(5) Guardian furnaces are very low in about every category and the PTFE media results in slightly lower 

emissions but about the same order of magnitude.

As mentioned above, we received the final Kingman furnace test report today. Next week, I will email 

the electronic pdf version of this report and also mail you a CD of the report in the abundance of 

caution.

Our test company is still working on the report in the ERT format and I will forward the ERT's to you 

when they arrive.

As we discussed, after we receive the final Inwood test report, which hopefully should be next week, I 

will complete populating Form C of the

114

survey request for each of the plants and forward this information to you.

Let me know if you have any questions.

Kind regards,

Grover Thomas

----- Forwarded by Grover Thomas/BP/Guardian_Industries on 03/02/2012

03:34PM ----- "Tony Blanton" <tony@integrityair.net>

To: <GroverThomas@bp.guardian.com>

 03/02/2012 02:55PM

cc "Jim Lewis" <jim@integrityair.net>

Subject: Inwood Results
Please respond to "Tony Blanton" <tony@integrityair.net>

Grover,

Please find attached the summary of results for the Inwood sampling. I should have the condensable 

portion of the 202 by Friday the 9th. I provided the filterable results so that you could compare Method 

29 to

5 /202.

Overall, the results look very good.

Thank you

Tony(See attached file: 26A.pdf)(See attached file: 29.pdf)(See attached

file: 0061.pdf)(See attached file: 5202.pdf) [attachment "26A.pdf" deleted by Susan 

Fairchild/RTP/USEPA/US] [attachment "29.pdf" deleted by Susan Fairchild/RTP/USEPA/US] [attachment 

"0061.pdf" deleted by Susan Fairchild/RTP/USEPA/US] [attachment "5202.pdf" deleted by Susan 

Fairchild/RTP/USEPA/US]